International Records Retention

International Records Retention

Background on Records Retention Generally

SUNY has a Records Retention Policy that codifies the retention periods for the various records housed by SUNY campuses.  The policy has a series of appendices (available through the policy and also on the Records Retention website) that list all the various records, and the specific period that a campus must retain them.  A complete listing of the Records Retention appendices is available here on SUNY’s Compliance Website.

This SUNY policy and appendices has been pre-approved by State Archives and OSC, and when they are followed proactively, they help SUNY to avoid risks on the back end, including data breaches and audit requests that span back farther than the SUNY schedule requires us to keep them for, and also helps to save on storage costs and IT costs.  More information on Records Management generally, and why it is a compliance concern, can be found on the SUNY Compliance Website Records Retention page.

When the SUNY Schedule does not cover a particular record, we are to defer to the New York State schedule (available on the State Archives website in PDF format) for the proper retention period.

International Student Records – 3 years

Our SUNY Student Records Schedule, which is an appendix to Policy 6609, states the following with regards to Student International records:

#24. Records of international students who enroll - 3 years
Including but not limited to: Copy of certificate of eligibility for F-1 visa status (form I-20, which also includes a statement of educational costs); Copy of Alien Registration Receipt Card (form I-551);3 years after graduation or date of last attendance (J-1) or 1 year after graduation or date of last attendance (F-1) .

This three year retention period is in accordance with applicable laws, and as such, it is appropriate for International Student Records to be purged three years after the student has left the institution.

#25 - Records of  international students who do not enroll - 3 Years
Including but not limited to: Copy of certificate of eligibility for F-1 visa status (form I-20, which also includes a statement of educational costs); Copy of Alien Registration Receipt Card (form I-551); Copy of “arrival-departure” record (form I-94); Copy of certificate of eligibility for J-1 visa status (form DS-2019); Statement of financial eligibility; Correspondence;3 years after application term (J-1) or 1 year after application term (F-1)

This three year retention period is in accordance with applicable laws, and as such, it is appropriate for International Student Records to be purged three years after the student has left the institution.

International Program Records – 6 years

Our SUNY Student Records Schedule, which is an appendix to Policy 6609, states the following with regards to International Program records:

#29 - International Program/Overseas Academic Program Records - 6 years
General correspondence pertaining to: Directors of International Education; Foreign Student Advisors; Foreign Student Admissions Officers; country files; foreign student scholarship and exchange programs, including agreements with foreign universities and other providers, tuition waivers; etc.

International Employment Records – 6 years

Our SUNY Student Records Schedule does not cover International Employment records.  Thus, we defer to the NY State schedule.  The State schedule does not specifically mention international records, but it does have a schedule item covering employment records generally.  The schedule states as follows:

90001 Personal History Files -- Records related to an individual's employment history with an agency. Personal history files generally include applications, résumés, appointment letters, probation reports, performance program evaluations, disciplinary actions, veterans status certifications, employee information forms, memoranda and correspondence related to employee, health insurance enrollment and declination records, retirement system declination forms, and survivors benefit information. Item can also be used for personal history files of volunteers and interns.

Minimum Retention and Disposition: Destroy 6 years after employee separation from agency, unless earlier disposition is permitted under terms of a labor-management contractual agreement.

This six year retention period does not conflict with any laws or regulations that would require us to hold onto international employment records for a longer period, as the laws and regulationsall call for less than six years. Thus, following the six year retention period for International Employment records is appropriate and in accordance with international law.

For questions related to Records Retention, contact the SUNY System Records Management Officer.

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The information contained on the SUNY Compliance website is for general campus guidance only and is not intended, nor can be relied upon, as legal advice or the imposition on SUNY campuses of specific policies or requirements. The site is intended to be an informational-only clearinghouse for some of the laws, rules, and regulations that may impact the State University of New York’s campuses. Additionally, given the rapid, changing nature of laws, rules and regulations, there may be delays or omissions contained on this site which therefore cannot be relied upon as complete. For complete compliance information, consult your campus compliance officials. For legal advice, consult your lawyer.

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